Serravalle Copper Tubes

Insight

EPD and CAM are not the same thing. The competitive advantage of an EPD-certified product.

EPD and CAM are not the same thing. The competitive advantage of an EPD-certified product.

When a procurement asks for “CAM-compliant” materials, it is not asking for certification: it is asking for proof. EPD is the strongest evidence there is, and it is the only one that works outside Italy as well.

Foreword

In many public tender specifications you will read the phrase “the product must comply with Building CAM.” Often the supplier replicates with a signed sheet where he or she declares compliance, sometimes accompanied by a stamp bearing words such as “CAM Certificate.” Well: neither of these two documents alone is legally sufficient in the new specifications based on Legislative Decree 36/2023 and Building CAM 2022 and 2026.

The reason is that CAM and EPD are not the same thing, nor are they equivalent. They are entities of a different nature: one is a set of requirements that public procurements must meet, the other is a third-party certified document that verifiably proves some of those requirements. Confusing them is a frequent but costly mistake: at the design verification or testing stage, a supplier who cannot provide the right proof stops the construction site.

This article explains the difference in operational terms, why it matters to those installing or designing ACR systems, and why having a product with EPD today is a strategic advantage-not just an ethical one.

1. What are CAMs and what they are derived from.

Minimum Environmental Criteria (CAM) are environmental requirements that public administrations must include in calls for tenders for works, service and supply contracts. They are not a certification, and there is no body that issues a “CAM mark.” These are regulatory requirements.

The legal framework is as follows:

  • Legislative Decree 221/2015, Art. 18: Introduces the obligation to include environmental criteria in public tenders.
  • Legislative Decree 36/2023 (new Public Contracts Code), Art. 57: makes the application of CAM a binding pillar for all public contracts.
  • Ministerial Decree 256 of June 23, 2022 (Building CAM 2022), as amended by Ministerial Decree August 5, 2024: defines specific criteria for the building sector.
  • Ministerial Decree November 24, 2025 (Building CAM 2026): further updates the criteria by aligning them with the EPBD IV Directive (“Case Green”) and the new European Construction Products Regulation (CPR 2024/3110).

CAM is organized into three families:

  • Technical specifications: mandatory minimum requirements that the product must meet.
  • Rewarding criteria: characteristics that, if possessed, increase the score of the bid.
  • Contract clauses: obligations that bind the contractor during performance.

For each criterion, the CAM defines what evidence is allowed to demonstrate compliance. And that is where EPD comes in.

2. What is an EPD

The Environmental Product Declaration**(EPD)**, or Environmental Product Declaration, is a documentary statement that reports the environmental impacts of a product throughout its life cycle, from raw material to end of life. It is regulated by two international technical standards:

  • ISO 14025: defines the general framework for Type III environmental declarations. “Type III” statements are those based on quantitative data, developed according to common rules and verified by an independent third party. They are distinguished from Type I declarations (EU Ecolabel-type eco-labels) and Type II declarations (producer self-declarations).
  • EN 15804: Harmonizes EPDs for the construction sector by defining Product Category Rules (PCRs)-that is, specific calculation rules for each category of building product. It is the reference standard for any EPD intended to document building products.

The EPD is based on a Life Cycle Assessment (LCA) study conducted according to ISO 14040/14044, which quantifies:

  • Resource consumption (raw materials, water, primary energy);
  • Climate-changing gas emissions (GWP, expressed in kg CO₂ equivalent);
  • other environmental indicators (acidification, eutrophication, tropospheric ozone, abiotic resource depletion, etc.);
  • Recycled material content and end-of-life recycling potential.

The data are organized by life cycle modules according to EN 15804: A1-A3 (production), A4-A5 (transport and installation), B1-B7 (use), C1-C4 (end of life), D (benefits beyond the system, e.g. material recovery).

Three points worth mentioning:

  • EPD is voluntary. No law forces a manufacturer to do this. Those who make it incur a cost by strategic choice.
  • EPD is specific to the individual product. A manufacturer does not have “a corporate EPD”-it has one for each product (or technically homogeneous family).
  • The EPD has a temporal validity. Typically five years, after which it must be renewed.

3. The relationship between CAM and EPD: WHAT vs. HOW.

The difference can be summarized as follows:

AppearanceCAMEPD
NatureRegulatory requirement for public procurementVoluntary technical declaration
What does it establishWhat the product must satisfyWhat the product contains and how much it impacts
Who issues itThe Ministry (decree)A manufacturer, validated by third party
Is it a certification?NoYes, Type III (ISO 14025)
ValidityPermanent until further decree5 years renewable
ScopeItaly (public procurement)International

The CAM says, “the product must have at least X% recycled matter, documented durability, low emissions in use.” The EPD says, “This product contains Y% copper from recycling, has a GWP A1-A3 of Z kg CO₂eq per kg, and an expected useful life of W years.” The first is the demand, the second is the proof.

More specifically, EPD is one of the means of evidence allowed by CAM to demonstrate compliance with certain criteria. Building CAM 2022 (under 1.3.4 on means of proof) and CAM 2026 list among the accepted documents:

  • Type III Environmental Product Declaration (EPD), compliant with UNI EN 15804 and UNI EN ISO 14025, such as EPDItaly or equivalent international schemes;
  • ReMade in Italy or Plastic Second Life certification (for recycled content);
  • UNI/PdR 88 (verification of recycled content);
  • EU Ecolabel or equivalent (for other criteria).

Simple self-declarations by the manufacturer unsupported by technical documentation certified by an accredited body are no longer allowed-this has changed in recent years.

4. What has changed with the Building CAM 2022/2024 and the new CAM 2026

Building CAM is not a static regulation. Recent evolution has three directions, all of which are relevant to those who supply or install plant components:

Enhanced traceability. CAM 2026 permanently eliminates the loopholes of self-declarations. Demonstrating the recycled matter content in a material or component requires a certified means of proof, and the Type III EPD is the most technically comprehensive because it documents not only the percentage of recycled material but the entire environmental profile.

Extension of LCA from product to building. Both CAM 2022 and CAM 2026 introduce rewarding criteria for projects that apply LCA at the building scale (UNI EN 15978). To conduct that analysis, the designer needs the EPDs of individual materials. A supplier who does not provide them subtracts points from the project.

Alignment with Europe. The new European Construction Products Regulation (CPR 2024/3110) will integrate EPD requirements into the Performance Declarations (DoPs) of CE-marked products in the coming years. EN ISO 22057:2022 also defines the data format for integrating EPDs into BIM models, as required by CAM 2026 for procurements falling under Art. 43 of Legislative Decree 36/2023.

In summary: The direction is clear. EPD is moving from a voluntary tool to a de facto required document, even where it is not yet formally mandatory.

5. Why having EPD products is a real competitive advantage

For an installation company or design firm, working with EPD-equipped products is not an ethical detail-it is an operational lever that translates into measurable benefits. Let’s look at them one by one.

5.1 Smooth access to public procurement

In post-D.Lgs. 36/2023 public tenders, the absence of valid means of proof may cause the bid to be excluded or its acceptance to be blocked. A company that routinely uses components with EPDs already has documentation ready, can respond to specifications without asking anything of the supplier, and goes through the verification phase without surprises. For a small or medium-sized company that does not have a structured race office, this is a significant operational savings.

5.2 Reward scoring in competitions

The CAM 2022 and 2026 reward criteria award additional points to:

  • Projects that demonstrate LCA at the building scale (UNI EN 15978);
  • Projects that exceed minimum recycled content thresholds;
  • bids that document low-impact design choices.

All these criteria are powered by product EPDs. A contractor proposing components with EPDs allows the designer to accumulate reward points that can be decisive in the award.

5.3 Credits in voluntary sustainability protocols.

The premium building and office segment is increasingly working with voluntary protocols such as LEED, BREEAM, ITACA, GBC Italia, DGNB. All of these schemes award specific credits for the use of materials with EPDs (e.g., LEED v4 – credit “Building Product Disclosure and Optimization – Environmental Product Declarations”). EPD-related credits can be worth up to 5-6 points out of 110 in the final tally of a LEED project. In a market where sustainability certification affects the real estate value and occupancy rate of an office building, these are points that matter.

5.4 NRP, NZEB and public funding

NRP-funded interventions and new NZEB (Nearly Zero Energy Buildings, mandatory for public administration from 2019 and private from 2021) are by definition subject to CAM and, in many measures, explicitly reward the availability of EPDs. The same applies to regional funds and calls on energy efficiency, where the presence of EPDs in installed materials is often an eligibility requirement or evaluation criterion.

5.5 Export and foreign markets

EPDs are mutually recognized among national programs (EPDItaly, EPD International, IBU, French INIES, and so on) through ECO Platform agreements. This means that an Italian installer designing or building works abroad, or working with international clients in Italy, speaks the same technical-environmental language everywhere. For example, the French FDES (Fiche Déclaration Environnementale et Sanitaire) is mandatory for building products sold in France and is based on the same EN 15804 system.

5.6 Value-added business argument

In a quote to a sustainability-conscious private customer, being able to state “the pipes we install have certified EPDs, contain X% recycled copper, have a GWP of Y kg CO₂eq per linear meter” is something that differentiates one bid from another. It is a tangible argument, not greenwashing.

6. The specific case of refrigeration and hydronic lines.

In the ACR industry, until a few years ago, EPD discourse was not mainstream because copper as a material itself had a good profile (100% recyclable without loss of properties, durability of decades) and the focus was on the thermal performance of the system. In recent years, with the growth in the weight of environmental criteria in tenders and the arrival of low-GWP refrigerants, the scenario has changed:

  • Recycled copper content becomes a measured and declared parameter. Copper is the building material with the highest recycling rate industry-wide, but it takes an EPD to verifiably declare it in specifications.
  • Compatibility with low-GWP refrigerants (R32 and especially R290 propane, GWP = 3) requires piping and insulation designed for A2L and A3 flammable gases-a parameter that affects safety and thus CAM related to the durability and safety of systems.
  • Documented durability is an explicit reward criterion. For a pre-insulated copper pipe with adhered sheathing, the expected service life documentation typically exceeds 50 years-a figure that, when included in EPD, is worth points.

In this context, SCT has developed SMISOL Clim Aeterna®, a pre-insulated system that brings all these elements into a single product: EPD according to EN 15804, compliance with Building CAMs, compatibility with R290, water vapor diffusion resistance factor μ > 45,000 (three times higher than the market standard for pre-insulated pipes), co-extruded sheathing adhered to copper during production (a topic we covered in a previous article on insulation adherence and energy efficiency).

For an installer or designer, choosing Aeterna in a public contract means having the documentation that the client will require ready to go, without having to chase after it.

7. What to ask the supplier (operational checklist)

For those who want to start working with EPD products in a structured way, here is a checklist to use when selecting suppliers:

Documents to be requested:

  • Copy of the product EPD (PDF), with registration number, verification body, validity date.
  • Indication of the EPD program of reference (EPDItaly, The International EPD System, IBU, etc.).
  • Declared compliance with EN 15804 (current A2 version) and ISO 14025.
  • Explicit indication of the life cycle modules covered (at least A1-A3; the best EPDs cover up to D).

Data to be extracted from EPD for specifications:

  • Total GWP (kg CO₂eq per declared functional unit).
  • Percentage of input recycled material.
  • Reference Service Life (RSL).
  • Indicators of acidification, eutrophication, abiotic resource depletion (ADP).

Consistency checks:

  • The functional unit stated in the EPD must be consistent with the use (e.g., linear meter of pipe installed, not kg of copper).
  • The issuance date must not be earlier than 5 years before the tender date.
  • The verification body must be accredited according to ISO 17029 or equivalent.

8. Conclusions

CAM establishes what a material or product must warrant in order to be used in a public procurement. The EPD is the most comprehensive and technically rigorous document to demonstrate those assurances. They are not the same thing: without CAM, EPD would be a purely marketing tool; without EPD (or equivalent), many CAMs would remain unverifiable requests on paper.

For a designer, working with EPD-equipped products means having documentary raw material to meet mandatory technical specifications, accumulating points on award criteria, feeding LCA at the building scale, collecting LEED/BREEAM/ITACA credits, and having no problems during verification. For an installation company, it means confidently participating in public tenders and presenting itself to the premium private sector with a solid business case.

The operational message is simple: over the next five years, the presence or absence of EPDs will make the difference between suppliers staying in the public market and suppliers leaving it. Starting now to favor products with certified EPD-even where it does not yet seem essential-means gearing up for a rapidly changing regulatory scenario, rather than chasing after it.

Normative references

  1. Legislative Decree 36/2023 – Public Contracts Code, Art. 57.
  2. M.D. 256 of June 23, 20 22 – Building CAM 2022 (amended by M.D. August 5, 2024).
  3. Ministerial Decree November 24, 2025 – Building CAM 2026.
  4. Legislative Decree 221/2015, Art. 18 – Environmental Provisions.
  5. Law Oct. 25, 2017 no. 163 – Assurance of compliance with CAM by the designer.
  6. EU Regulation 2024/3110 (CPR) – European Construction Products Regulation.
  7. Directive (EU) 2024/1275 (EPBD IV) – Energy performance in buildings.

Technical references

  1. ISO 14025 – Environmental labels and declarations – Type III environmental declarations.
  2. EN 15804+A2 – Sustainability of construction works – Environmental product declarations – Core rules for the product category of construction products.
  3. ISO 14040 / ISO 14044 – Life Cycle Assessment – Principles, framework and requirements.
  4. EN 15978 – Sustainability of construction works – Assessment of environmental performance of buildings.
  5. EN ISO 22057:2022 – Sustainability in buildings and civil engineering works – Data templates for EPDs.
  6. UNI/PdR 88 – Verification of recycled and/or by-product content in construction materials.
  7. ISO 17029 – Conformity assessment – General principles and requirements for validation and verification bodies.

Benchmark EPD programs